The Director of Animal Welfare, Norma Worley, is trying to change the rabies immunization requirement for puppies from 6 months to 3 months despite the fact that Maine hasn't had a documented case of a rabid dog since 2003 and there have only been 5 documented cases since 1994 (14 years), and none of them were noted as being puppies.

Please read the testimony I presented in opposition to Section 7 of LD 2171 at yesterday's hearing before Maine's Agriculture Committee. If you are concerned about this and wish to voice your opposition, PLEASE e-MAIL THE COMMITTEE members by cutting and pasting their addresses below and putting something like Oppose LD 2171 Section 7 in your subject line.

The committee wants to hear from the dog-owning public, and if it doesn't, you may end up being required to add a rabies vaccine into the mix of puppyhood shots (distemper, hepatitis, parvo, etc..) that are being administered at that age.

My name is Kris Christine and I live with my family in Alna, Maine. I am the Founder and Co-Trustee of The Rabies Challenge Fund (RCF). My colleagues -- Dr. W. Jean Dodds of Hemopet, Co-Trustee of the RCF and Dr. Ronald Schultz of The University of Wisconsin School of Veterinary Medicine, currently conducting 5 & 7 year rabies challenge studies for the RCF -- are the world’s two leading veterinary vaccine research scientists.

I am here to testify against Sec. 7. 7 MRSA §3916, sub-§1-A of LD 2171, which would amend the law to require that puppies be vaccinated against rabies at 3 months of age rather than 6.

There is no scientific or epidemiological data justifying amendment of this law as there has been no increase in rabies in puppies under the age of 6 months in the State of Maine. Dr. Donald Hoenig, Maine’s State Public Health Veterinarian, told me on Wednesday, February 6th that “The last case of canine rabies in Maine was in 2003.......there have only been 5 cases of canine rabies in the past 14 years in Maine…….Cases of canine rabies are EXTREMELY UNUSUAL.”

Five cases of rabies in dogs since 1994 (no mention was made of these cases being puppies under 6 months of age), with the last one being in 2003, evidences the fact that the current law requiring puppies be vaccinated against rabies at 6 months of age is effective at controlling rabies in Maine’s canine community and does not need to be changed.

Vaccinating puppies at too young an age can be ineffective. The 2003 American Animal Hospital Association's (AAHA) Canine Vaccine Guidelines reports on Page 17 (Attachment #1) that: “…when puppies are first vaccinated at > 16 weeks of age (an age when passively acquired antibodies generally don’t cause interference), one dose of an MLV vaccine, or two doses of a killed vaccine, are adequate to stimulate an immune response.”

On Page 16 of the 2003 AAHA Guidelines (Attachment #2), it states that: "When vaccinating an animal, the age of the animal, the animal's immune status, and interference by maternal antibodies in the development of immunity must be considered. Research has demonstrated that the presence of passively acquired maternal antibodies interferes with the immune response to many canine vaccines, including CPV, CDV, CAV-2 and rabies vaccines."

The 2006 AAHA Guidelines (Attachment #3), states on Page 13 as the most common reason for vaccination failure that “the puppy has a sufficient amount of passively acquired maternal antibody (PAMA) to block the vaccine......"The older the puppy is when it receives its first rabies vaccination, the more likely it will elicit the desired immunological response – as demonstrated by the extraordinarily low number of canine rabies cases in Maine over a 14 year period under the current 6 month vaccination protocol for puppies.

Rabies, a “killed” vaccine, is the most potent of the veterinary vaccines and is associated with clinically significant adverse reactions -- it should only be given when warranted. According to the 2003AAHA Guidelines (Page 16) (Attachment #2), "...killed vaccines are much more likely to cause hypersensitivity reactions (e.g., immune-mediated disease)." Further, the AAHA task force reports on Page 18 (Attachment #4) that, "Bacterial vaccines, especially killed whole organism products …..are much more likely to cause adverse reactions than subunit or live bacterial vaccines or MLV vaccines, especially if given topically. Several killed bacterial products are used as immunomodulators/adjuvants. Thus, their presence in a combination vaccine product may enhance or suppress the immune response or may cause an undesired response (e.g., IgE hypersensitivity or a class of antibody that is not protective)."

In sum, the law, as it currently stands requiring puppies to be vaccinated at 6 months of age is and has been effective at controlling rabies in Maine’s canine population. There is no epidemiological or scientific rationale for changing this law and prematurely exposing puppies to the potentially harmful, sometimes fatal, adverse side affects of the rabies vaccine prior to the age of 6 months.